ML18089A380

Supplemental Application to Amend Licenses DPR-70 & DPR-75, Revising Tech Specs Re Administrative Controls for Overtime Limitations,Porv & Safety Valve Challenge/Failure Reporting & Audits

ML18089A380
Person / Time
Site:	Salem
Issue date:	09/23/1983
From:	Liden E Public Service Enterprise Group
To:	Varga S Office of Nuclear Reactor Regulation
Shared Package
ML18089A381	List: ML18089A380 ML18089A382
References
LCR-81-19, NUDOCS 8309300269
Download: ML18089A380 (10)

Text

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Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New'Jersey 08038 Nuclear Department Ref: LCR 81-19 (Rev. 1)

September 23, 1983 Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, Maryland 20014 Attention: Mr. Steven Varga, Chief Operations Reactors Branch 1 Division of Licensing Gentlemen:

PAGE REVISIONS TO REQUEST FOR AMENDMENT TO FACILITY OPERATING LICENSES DPR-70 AND DPR-75 UNIT NOS. 1 AND 2 SALEM GENERATING STATION DOCKET NOS. 50-272 AND 50-311 The attached modifications to the description and safety evaluation sections of our previously submitted amendment request (LCR 81-19) provides additional details and amplifying material. For continuity, unaffected pages from the amendment request are also included so that the entire section can be replaced with the attached pages 1 through 8. Modifications are identified by a vertical line in the right hand margin.

Additionally, a minor change to our Station Operations Review Committee (SORC) composition has been made to reflect the latest membership.

Very truly yours, 8309300269 830923 PDR ADOCK 05000272 p PDR

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Manager - Nuclear Licensing and Regulation Attachment The Energy People 95-2168 (SOM) 11-82

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Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 9/23/83 CC: Mr. Donald C. Fischer Licensing Project Manager Mr. James Linville Senior Resident Inspector Mr. Frank Cosolito, Acting Chief Bureau of Radiation Protection Department of Environmental Protection

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Ref: LCR 79-01 (Rev. 1)

LCR 81-19 (Rev. 1)

PROPOSED CHANGES TECHNICAL SPECIFICATIONS UNIT NOS. 1 AND 2 DESCRIPTION OF CHANGE The proposed changes contained herein revise two previously submitted amendment requests which incorporated the principles of 10 CFRSO, Appendix I (LCR 79-01) and involved organizational changes in the Administrative Controls section (LCR-81-19).

Additionally, these proposed changes add requirements in the Administrative Controls section concerning overtime limitations, PORV and safety valve challenge/failure reporting and audits.

DISCUSSION OF SPECIFIC REVISIONS Overall Comment - Previous LCR's 79-01 and 81-19, affect many sections of the Technical Specifications. In the interest of continuity and clarity, both units' Administrative Controls sections have been retyped in their entirety to make them, as much as possible, read the same. The INDEX and DEFINITIONS sectiorts.have also been retyped/alphabetized to make them consistent and easier to use.

LCR 79-01 (Rev. 1)

This change revises appropriate sections of the Salem Nuclear Generating Station Technical Specif ictions to incorporate the principles of 10CFR 50, Appendix I. This change also deletes "Part 1-Radiological" of the Environmental Technical Specifications and incorporates the salient items of this section into Appendix A of the Salem Operating License.

Revised License Change Request 79-01 was developed using the guidance provided in NUREG-0472, Rev. 3, and constitutes the PSE&G version of the standard Radiological Effluent Technical Specification (RETS).

LCR 81-19 (Rev. 1) 6.2 ORGANIZATION - The Nuclear Department structure, which resulted from an organizational review of our nuclear operation and support staff, is depicted in the Organization Charts, Figure 6.2.1, CORPORATE HEADQUARTERS AND OFFSITE ORGANIZATION FOR MANAGEMENT AND TECHNICAL SUPPORT and Figure 6.2.2, FACILITY

Page 2 ORGANIZATION. Title changes and the shifting of functional responsibilities and authority are reflected throughout Section 6.0, Administrative Controls, and are indicated by vertical lines in theright hand margin next to the changes.

6.2.2.f Facility Staff - A statement concerning limitation of overtime has been added in accordance with Generic Letter 82-12.

6.5.1.2 - SORC composition has been modified to add the Safety Review Engineer and adds the Station Planning Engineer vice the Senior Radiaiton Protection Supervisor.

6.5.2.8 Audits - Audit frequencies for the Facility Security Plan and Facility Emergency Plan have been changed from 24 months to 12 months to bring them into conformance with 10CFR50 and 10CFR73 requirements.

6.9.1.6 Monthly Operating Report - Added to the routine monthly operating statistics and shutdown experience, will be a report of all challenges to PORV's or safety valves. ~ailures of the safety valves will be reported under the existing requirements of Section 6.9.1.7 and 6.9.1.8.

REASON FOR CHANGE LCR-79-01 (Rev. 1)

In keeping with USNRC efforts to standardize all nuclear power plant Technical Specifications, PSE&G has been requested to implement the specifications which they developed. An earlier version of this amendment was originally prepared and submitted to the USNRC on November 26, 1979. As a result of the accident at Three Mile Island, the Nuclear Regulatory Commission has not actively reviewed our proposed Effluent Technical Specif ica-tions. The USNRC is now prepared to fully review our submittal and has requested that we resubmit our proposed changes updated with the guidance provided by the USNRC in Revision 3 to NUREG 0472.

LCR 81-19 (Rev. 1)

As a result of the experience gained in the operation and technical support of the Salem units and our continuing desire to improve the efficiency and effectiveness of these functions, a review was performed of the structure and capability of our nuclear operations and support organizations. Considered in detail in this review were the many requirements and

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Page 3 recommendations that have come forth from the post-TMI assessment of the nuclear industry, as well as the specific observations made by both NRC and INPO.

The results of this organizational review led to the integration, within a centralized Nuclear Department, of a major portion of PSE&G's nuclear operations and support functions. To improve the dedication and responsiveness of support personnel to plant operations, this new department has been located directly at the Artificial Island site. This action enhances our state of emergency preparedness, and enables us to more effectively satisfy the requirements of NUREG-0654 (Criteria for Preparation and Evaluation of Radiological Emergency Response Plans).

This revision makes several changes and additions that reflect organizational modifications and/or respond to specific NRC requirements that have developed since our original submittal of this LCR.

SAFETY EVALUATIONS LCR 79-01 (Rev. 1)

This proposed amendment to the Salem Nuclear Generating Station Technical Specification incorporates the requirements of Appendix I 10CFRSO and clarifies certain aspects of our exist-ing Environmental Technical Specifications. The changes being proposed in this license change request will not result in any reduction in the levels of safety already provided by the existing technical specifications. The changes being proposed will tend to strengthen many of the surveillance requirements for instrumentation and, in general, will tend to increase the margin of safety already provided. The following is a summary of key changes being proposed, along with our evaluation of why margins of safety have not been reduced:

License to provide specification of the alarm/setpoints for certain effluent radiation monitors.

Current technical specifications for the Salem station do not require that setpoints be provided for effluent channels. This change will require that alarm/trip setpoints be provided in a separate document called an Off-site Dose Calculation Manual.

The setpoints in this document will be reviewed by the USNRC prior to implementation. This change will result in additional surveillance; hence, it will not decrease the margin of safety already provided in the technical specification.

Page 4 Amend license to require several gaseous and liquid process instruments to be operational and in addition required that explosive gas mixtures be continuously monitored.

Gaseous and liquid process instrumenation at the Salem Station will be maintained and operated when necessary to process radioactive waste. Current technical specifications do not clearly specify what action should be taken when radiation monitoring equipment is temporarily unavailable. New technical specifications will clearly specify what actions will be taken. In addition, the technical specifications will call for continuous surveillance of explosive mixtures of hydrogen and oxygen in the gaseous waste holdup system. This change will increase the margin of safety already provided in the technical specifications.

Amend the Salem license to remove curie limitations and replace them by dose limitations.

Curie limitation are no longer required by the USNRC and have been replaced by dose limitation. Expressing environmental impact in units of curies is not sufficient alone to determine off-site environmental impact from radioactive releases. The NRC has recognized that it is more appropriate to express environmental impact in terms of cumulative dose. Operation of radwaste equipment will be based on cumulative dose delivered to man and not upon exceeding a curie limit.

Amend the Salem license to require the maintenance of document called an Offsite Dose Calculation Manual (ODCM).

The creation of a manual called an ODCM will clearly specify how PSE&G will determine radiation dose to the public. This document must also be approved by the USNRC before implementation. The amendment of the Salem license to include this document will not reduce any of the safety margins which currently exist.

We have determined that this change involves no significant hazards consideration in that it would not:

(1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) Create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) Involve a significant reduction in a margin of safety.

Page 5 LCR 81-19 (Rev. 1)

These proposed changes are administrative in nature and have been determined to involve no significant hazards consideration in that they would not:

(1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) Create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) Involve a significant reduction in a margin of safety.

The change to the Station Operations Review Committee reflects the latest membership and adds the Safety Review Engineer. The limitation on overtime, which complies with the guidance of Generic Letter 82-12; the change from a 24 month to a 12 month audit frequency for the Facility Security Plan and Facility Emergency Plan, which conforms to 10CFR 50 and 10CFR 73 requirements; and the reporting of PORV/safety valve challenges/

failures, each incorporate additional limitations and restrictions on the Facility Operating License to improve overall plant safety.

The functions performed by the proposed Nuclear Department organization are the same as were performed by various departments at the plant and corporate headquarters prior to the formation of the new organization. Functional responsibilities and authority levels have been reassigned within the Nuclear Department support organizations to reduce the non-operational workload of plant management while combining these organizations into a single, centralized, integrated structure. Headed by a Vice President as the senior nuclear manager, this organization clearly established the responsiblity for safe and efficient operation of our nuclear facilities. It also provides for unambiguous management control and effective lines of authority and communication between responsible groups involved in the management, technical and administrative support and operation of our nuclear units.

The strength and effectiveness of this organization resides in five key senior management positions providing the overall management direction and control of the Company's nuclear programs. These positions, Vice President - Nuclear, General Manager - Salem Operations, General Manager - Hope Creek Operations, General Manager - Nuclear Support and General Manager

- Nuclear Services are further described below in terms of functional responsibility and authority.

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Page 6 Vice President - Nuclear The Vice President - Nuclear is the senior nuclear manager in overall charge of our nuclear programs at Artificial Island, including plant operations and nuclear safety. The General Manager - Salem Operations, General Manager - Hope Creek Operations, the General Manager - Nuclear Support and the General Manager - Nuclear Services report directly to the Vice President - Nuclear. It is expected that the total work force will number approximately 1400 persons by the time of commercial operation of the first unit at Hope Creek. In the event of a nuclear emergency at Artificial Island, the Vice President - Nuclear assumes the role of Emergency Response Manager and takes command and control of all PSE&G on-site and off-site response activities. Additionally, the Vice President -

Nuclear establishes policies on nuclear operations matters within the Company, subject to the advice and consent of senior corporate manangement. Where questions or disagreements arise within the nuclear organization concerning nuclear safety matters, the Vice President - Nuclear Department will establish Company policy. In addition, he has the authority and responsibility to determine when the plants must be shut down to maintain the safety of the facilities.

As the senior nuclear manager in overall charge of Company nuclear programs, the Vice President - Nuclear provides management direction and control for the operation and support activities associated with our nuclear facilities at Artificial Island. This includes the establishment of qualification requirements for management positions which directly support plant operations, the development of goals, objectives andCompany policy relating to the safe and reliable operation of the nuclear units, and implementation of formalized programs, such as security, fire protection, radiation protection, and operator training.

The senior nuclear manager is actively involved in plant operational activities and reviews significant operating deficiencies and violations of Technical Specifications. He monitors the activities of the Nuclear Review Board that perform the independent review function of important matters affecting nuclear operation and safety. Close attention to unanticipated and unusual plant occurrences and review of operational trend analysis by the senior nuclear manager assures that the highest standards affecting plant operations ~re maintained.

Reporting directly to the Vice President - Nuclear is the Manager - Methods and Administration - Nuclear, who is responsible for planning and scheduling, cost control, systems development, computer applications, and coordination of all personnel and administrative functions including payroll, accounting, employment and compensation, and medical services.

Page 7 General Manager - Salem Operations General Manager - Hope Creek Operations The General Manager for each nuclear station is responsible for the safe and efficient operation of the nuclear units and general direction of the Operating, Maintenance, Radiation Protection andTechnical Support Departments. This encompasses a plant staff inexcess of 400 employees. Reporting directly to the station General Manager is an Assistant General Manager, followed by four major station department heads, the Operating Manager, Maintenance Manager, Technical Manager, and Radiation Protection Engineer.

The General Manager is responsible for compliance with all applicable requirements of the NRC Operating License and Technical Specifications, and the prompt reporting of unusual events, deficiences and corrective action implementation. He monitors the activities of the Station Operations Review Committee (SORC), involving evaluations of plant safety related activities. Additionally, he is responsible for assuring that the nuclear station needs for engineering, maintenance and other site support services are identified and can be adequately satisfied by the site support organizations to meet all requirements for safe and reliable plant operation.

The General Manager is responsible for assuring that plant staff positions are maintained by fully qualified and trained personnel. He directs the implementation of a radiation protection program that assures that radiation exposure of plant and support personnel is maintained as low as reasonably achievable. He is also responsible for the approval of operating procedures as required by Technical Specifications and for the development and control of budgets for the operation and maintenance of the station.

General Manager - Nuclear Support The General Manger - Nuclear Support is responsible for providing support to the nuclear stations in the areas of engineering and design, reactor engineering and fuel management, the maintenance of the operating licenses, and review of the investigations conducted by the Safety Review Group. In addition, he provides support for the Nuclear Department concerning public relations, public information, and the operation of the Site Nuclear Information Center.

The station General Manager will direct the General Manager -

Nuclear Support to provide assistance for performance of the required work in these areas of responsibility. The General Manager - Nuclear Support will make the determination of which

Page 8 activities are performed by on-site and/or off-site personnel, and furthermore provide technical direction for all off-site support functions performed in these areas. All off-site communications regarding these areas of responsibility shall be through the Nuclear Support Department.

Reporting directly to the General Manager - Nuclear Support are the Safety Review Group; three department managers responsible for licensing and regulation, nuclear safety and assessment, and fuel cycle; and the Assistant General Manager - Nuclear Engineering who, in turn, directs four additional department managers whose responsibilities include plant systems, engineering and design.

General Manager - Nuclear Services The General Manager - Nuclear Services is responsible for providing technical support to the station organizations in the area of radiation protection; site protection including fire, security and emergency preparedness; training of licensed and non-licensed personnel; in-service inspection and non-destructive examination.

This organization also provides the stations with calibration and instrument repair, radwaste management, and maintenance support services. In addition, he is responsible for material management, warehousing and control of all contractor activities.

The station General Manager will direct the General Manager -

Nuclear Services to provide assistance for performance of the required work in these areas of responsibility. The General Manager - Nuclear Services will make the determination of which activities are performed by on-site and/or _off-site personnel, and furthermore provide technical direction for all off-site support functions performed in these areas. All off-site communications regarding these areas of responsibility shall be through the Nuclear Services Department.

Reporting to the General Manager - Nuclear Services are six department managers who provide services to the two nuclear stations. Under the direction and control of the ~eneral Manager - Nuclear Services, common activities required by both nuclear stations are combined to provide improved utilization of resources and greater control of the identified support functions.

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